March 23, 2023

 

Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

 

Regarding: Letter Dated December 6, 2022

 

Form 8-K filed on August 15, 2022

 

Form 8-K filed on August 15, 2022

 

Reconciliation of Adjusted EBITDA to Amounts Reported Under U.S. GAAP, page 8

1. We note your response to comment 11. We continue to believe that your adjustment to

exclude mine development costs is inconsistent with the guidance in Question 100.01 of

the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please

confirm to us that you will no longer include the adjustment in any non-GAAP financial

measures and revise to present your measure in accordance with Item 10(e) of Regulation

S-X and Regulation G.

 

Response: We agree with the comment and have revised our filing accordingly. Additionally, we have submitted a draft of the 2022 earnings 8-K for review.

 

 

 

Regards,

 

Kirk P. Taylor, CPA

Chief Financial Officer

American Resources Corp